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                           FULBRIGHT & JAWORSKI L.L.P.
                   A Registered Limited Liability Partnership
                          666 Fifth Avenue, 31st Floor
                          New York, New York 10103-3198
                                www.fulbright.com

NEIL GOLD                                          DIRECT DIAL:   (212) 318-3022
PARTNER                                            TELEPHONE:     (212) 318-3000
NGOLD@FULBRIGHT.COM                                FACSIMILE:     (212) 318-3400

October 20, 2005

VIA FEDERAL EXPRESS

Mr. Larry Spirgel
Assistant Director
Securities and Exchange Commission
Division of Corporation Finance
450 Fifth Street, N.W.
Mail Stop 03-05
Washington, D.C.  20549-0305

         Re:      Orckit Communications Ltd.
                  Form 20-F for the Year Ended December 31, 2004
                  File No. 000-28724
                  ------------------

Dear Mr. Spirgel:

         On behalf of Orckit Communications Ltd. (the "Company"), we hereby
submit to you the Company's responses to the additional comments of the Staff
set forth in its letter dated October 6, 2005 relating to the Company's Form
20-F for the year ended December 31, 2004 (the "Form 20-F").

         All responses to the comments set forth in this letter are submitted on
behalf of the Company at its request. All responses were prepared by the Company
in consultation with its independent auditors. Set forth after each italicized
paragraph are the Company's responses to the Staff's comments.

                  Refer to the second paragraph of your response to comment 6,
         which indicates that the revenues and costs in question are parts of
         multiple element arrangements. Tell us the amounts of these deferred
         costs that are off-set against deferred revenues at each balance sheet
         date.

Houston o New York o Washington DC o Austin o Dallas o Los Angeles o Minneapolis o San Antonio o Hong Kong o London o Munich

Mr. Larry Spirgel
October 20, 2005
Page 2

         Response:
         ---------

         Total cost of goods sold that was offset against deferred revenues as
of December 31, 2004 was $38,829,000. As of December 31, 2003, there were no
deferred revenues and, accordingly, no offset.

                  Clarify whether or not it is appropriate to expense these
         costs upon delivery.

         Response:
         ---------

         The Company does not believe it is appropriate to expense these costs
upon product delivery since these expenses are costs of the products and,
therefore, until the revenues from the sale of the corresponding products are
recognized, these costs should not be expensed.

                  Explain in more detail why you do not believe that these
         deferred costs qualify as assets

         Response:
         ---------

         In standard circumstances, once the Company recognizes revenues it
records the relevant revenues against cash or receivables, and transfers the
relevant costs from inventories to cost of revenues. In this specific case, the
Company reached the conclusion that due to the absence of objective and reliable
evidence of fair value of the undelivered element i.e., post contract services
("PCS"), as explained in the notes to the financial statements and in the prior
response to comment 6, these revenues must be deferred and recognized ratably
over the maintenance period, when the PCS is provided. Hence, deferral of the
related cost of goods sold is appropriate. However, the Company believes that
presenting such cost of goods sold as inventory (i.e., as an asset) in this
specific case is incorrect, since the title to these products has passed to its
customer and the only reason for deferral is due to accounting requirements. In
such a case, the Company believes that the correct presentation is to offset
these cost of goods sold against the corresponding deferred revenues rather than
presenting these deferred costs as an asset. Such presentation indicates that
the products have been delivered to the customer and the Company deferred the
gross margin to be recognized in future periods. Note 9 g to the Company's
financial statements discloses the components of the net amount.

                  Explain whether each of the types of costs listed in the first
         paragraph of your response to comment 6 are incremental and direct
         costs related to a specific contract or arrangement

Mr. Larry Spirgel
October 20, 2005
Page 3

         Response:
         ---------

         Each of the items in the first paragraph of the Company's response to
comment 6 represents the cost of goods sold and are incremental and direct costs
related to products and services delivered.

                  Describe how these costs relate to the deferred multiple elements

         Response:
         ---------

         All of the costs that were deferred and offset against the deferred
revenues represent cost of goods sold of the corresponding products and services
(multiple elements) of which revenues were deferred. Costs of components and
subcontractors (clauses a and b in the first paragraph of the Company's response
to comment 6) relate to each product component delivered, namely each module of
assembled printed circuit board and chassis. All of these costs are incurred on
a per unit basis. Costs of operational activity (clause c in that paragraph)
relates to costs for operational support personnel and related costs for the
delivery of the products. Post Contract Services (PCS) and warranty costs
(clauses d and e in that paragraph) are support costs relating to software and
hardware that are expected following the delivery of the products and need to be
provided for in connection with revenue recognition. Royalties to the Israeli
OCS (clause f in that paragraph) are costs payable and provided for in
connection with revenue recognition.

                  Identify which of these costs relate to sales that are
         effectively consignment sales

         Response:
         ---------

         None of the Company's sales was on consignment basis. Therefore, none
of these costs related to any consignment sale.

                  Identify incurred losses that are considered an investment in
         the remainder of the contract as supported by the revenue allocated to
         the remaining deliverables being an amount greater than the fair value
         of those deliverables

         Response:
         ---------

         The Company has not incurred any losses with respect to any of these
sales in the year ended December 31, 2004. Accordingly, none of the costs is
considered an investment. In previous years, the Company did not defer any
revenues and, therefore, there are no incurred losses that were considered an
investment.

                  Identify those incurred costs that are contractually
         guaranteed reimbursable costs

Mr. Larry Spirgel
October 20, 2005
Page 4

         Response:
         ---------

         None of the costs incurred are contractually guaranteed reimbursable
costs.

                  We do not believe that Rule 5-02.6(d)(iii) is applicable to
         the display of these items. Consequently, the staff believes these
         costs and deferred revenues should not be offset unless a right of
         setoff exists.

         Response:
         ---------

         Rule 5-02.6 (d) (iii) was mentioned by the Company merely as an
analogy. As explained above, the Company believes that deferred costs related to
deferred revenues should not be viewed as an asset. As title to such products
has passed to the customer (legally and contractually), the Company has netted
the cost of goods sold of the products against the corresponding deferred
revenues, similar to the guidance Rule 5-02.6 (d) (iii) sets forth in connection
with other circumstances.

         The Company believes that the proper accounting treatment is to defer
the gross margin of these transactions (revenues net of costs). Once the
accounting criteria for revenue recognition are met, the deferred gross margin
will be grossed up, and the applicable revenues and costs would be recognized in
the Company's statement of operations.

         If you have any additional comments or questions, please feel free to
contact the undersigned at (212) 318-3022 or Anthony Saur at (212) 318-3172.

                                  Very truly yours,

                                  /s/ Neil Gold

                                  Neil Gold

cc:      Andrew Mew
         Joseph Kempf
         Aviv Boim